Reporting Uncertain Tax Positions: Implications of the New IRS Return Schedule
Preparing for New Transparency Demands and Managing Disclosure Risks
Recording of a 110-minute CLE webinar/teleconference with Q&A
Conducted on Thursday, May 6, 2010
Recorded event now available
This CLE webinar will prepare corporate tax professionals to comply with coming IRS policy on reporting uncertain tax positions and give insights into how to calculate maximum tax liability and describe each reserved position. The panel will also explain the potential risks to previously protected workpaper information.
Description
No federal income tax regulatory development in recent months has been more significant than the IRS plan, as stated in Announcement 2010-09, to make companies with more than $10 million in assets disclose all uncertain tax positions in a new schedule to be filed along with their returns.
By insisting that taxpayers report even those uncertain positions for which no reserve exists, the IRS requirement will surpass FIN 48. Also, companies will need to state maximum federal tax liability for each position (without regard to a risk adjustment) and disclose some unreserved positions.
In short, the IRS is imposing an entirely new process on corporate tax departments, and prudent tax professionals must prepare now. The April 19, 2010 publication of draft Schedule UTP and its instructions provides sufficient detail on the coming mandate to start that planning.
Listen as our panel of veteran federal tax advisors analyzes the new reporting regimen for uncertain tax positions and helps you strategize for proper compliance right from the start.
Outline
- Key terms of IRS Announcement 2010-9
- Disclosure of “uncertain tax positions” on new schedule accompanying returns, to also include:
- Code sections potentially affected by position
- Description of tax years affected
- Statement that position involves item of income/gain/loss/deduction/credit
- Statement that position involves permanent inclusion or exclusion of any item
- Statement of whether position involves determination of value of any property or right
- Statement whether position involves computation of basis
- Disclosure of maximum federal tax liability for each position
- Consideration of possible failure-to-file or non-disclosure penalties
- Disclosure of “uncertain tax positions” on new schedule accompanying returns, to also include:
- Potential implications
- Possible ties to Textron case and policy of restraint
- Timing and wording of disclosures
- Would risk assessments or tax reserve amounts have to be disclosed?
- What competitors and auditors could do with information
- How states will react and choose to track IRS policy
Benefits
The panel will address these and other key issues:
- Calculating the maximum amount for each uncertain tax position, given the lack of a materiality requirement and the inherent complexity in valuing certain exposures.
- Meeting the requirement for a "concise description" of each reserved position.
- Evaluating whether this new policy will undermine the IRS' policy of restraint with regard to tax workpapers given that core information would be included with a tax return.
Upon completion of this seminar, an attendee will be better prepared to comply with the new IRS schedule and regs on uncertain tax positions in advance of their publication.
Faculty
Robin Greenhouse,
Tax Partner
McDermott Will & Emery, Washington, D.C.
She represents clients on major tax controversies with the IRS at audit or appeals, and in tax litigation before the U.S. Tax Court and other federal courts. She previously worked as a trial lawyer with the U.S. Department of Justice, Tax Division.
Todd Simmens,
Partner and National Director, Tax Controversy and Procedure
BDO USA, Washington, D.C.
He focuses on assisting clients with tax disputes, IRS procedure and penalties, and reportable transaction rules. He previously served as legislative counsel for the U.S. Congress Joint Committee on Taxation.
Ronald Kerridge,
Partner
K&L Gates, Dallas
He works in both tax controversies and transactional tax matters, principally on corporate and individual taxpayer issues before the IRS.
Adam Tejeda,
Attorney
K&L Gates, New York
He works with clients on a wide range of tax matters associated with domestic and international business transactions, principally in the corporate and partnership taxation arenas.
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Customer Reviews
Very interesting, informed us on the most recent updates.
Kristin Thompson
Global Tax Management
I liked that the program went beyond the guidance in the regs to offer a real-world perspective.
Jerry Bourlier
Yazaki Management Co.
Offered different view points and real life, practical examples.
Angela Chretin
Northrop Grumman
Timely coverage of a complicated subject.
William Ahlstrom
Kerber Eck & Braeckel
This teleconference greatly helped us understand the new challenges.
Andrew Toth
Tronconi Segarra & Associates
Federal Income Tax Advisory Board
David Bowen
Principal
Grant Thornton
Joseph Calianno
Partner, National Tax Practice
Grant Thornton
Of Counsel
Morrison & Foerster
George Manousos
Partner
PricewaterhouseCoopers
Federal Tax Partner
Nixon Peabody
Tax Controversy Partner
Crowell & Moring
Of Counsel
Skadden Arps
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey
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